Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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HC dismissed revenue's challenge and upheld the concurrent factual findings of CIT(A) and the ITAT that the assessee satisfied conditions for deduction under section 80IB(10), the approved plan showing each residential unit under 1,000 sq. ft. The court held the dispute over comparative sale rates and valuation (including terrace access) raised no question of law or substantial question of law, and that differences in sale prices vis-Ã -vis stamp rates did not permit an inference of cash transactions without further evidence. Consequently, there was no perversity warranting interference under section 260A of the IT Act, and the appellate and tribunal conclusions were sustained.
HC dismissed revenue's challenge and upheld the concurrent factual findings of CIT(A) and the ITAT that the assessee satisfied conditions for deduction under section 80IB(10), the approved plan showing each residential unit under 1,000 sq. ft. The court held the dispute over comparative sale rates and valuation (including terrace access) raised no question of law or substantial question of law, and that differences in sale prices vis-Ã -vis stamp rates did not permit an inference of cash transactions without further evidence. Consequently, there was no perversity warranting interference under section 260A of the IT Act, and the appellate and tribunal conclusions were sustained.
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